Tying Compliance with CARB’s Truck and Bus Regulation to

DMV Registration Informational UpdateDecember 14, 2018

Presentation Overview

New Law requires compliance for registration Truck and Bus Regulation (T&B) Overview Compliance Challenges New Law Implementation Enforcement Activities Next Steps

2

New Law Requires T&B Compliance for DMV Registration

3

Requires compliance demonstration prior

to registration

Phases in verification starting January 1, 2020

Allows for temporary permits to operate while issues are

resolved

Who Will Be Affected?

2023 is the final deadline for engine replacement

Many fleets need to take action from 2020-2023 to stay in compliance

4

0100002000030000400005000060000700008000090000

100000

2020 2021 2022 2023

Num

ber o

f Tru

cks

Truck and Bus RegulationApproved in 2008 to protect health by reducing exposure to harmful particulate matter (PM) and oxides of nitrogen (NOx) emissions from trucks and buses

Critical component of CARB’s Diesel Risk Reduction PlanCenterpiece of 2023 SIP strategy

5

Applies to the 1M trucks and buses operating in CaliforniaMedium- and heavy-

duty trucks and buses400K registered in CA 600K registered out of

state

Compliance Assistance

6

General• TruckStop website• Deadline reminders• Funding outreach• Truck Loan Program

One-on-One• Diesel Hotline calls:

60,000-80,000 per year• Emails: 20,000 per year• Training classes & events:

50 per year

Compliance has been a Challenge

Most fleets operating in California are small businesses - 20 or fewer trucks.

Recession significantly impacted the trucking industry, reducing new vehicle sales, and impacting fleets’ abilities to comply

7

Regulation amended in response to comments and feedback from industry to provide flexibility

Statewide PM2.5 Emissions from Vehicles Subject to T&B Rule

8

Emissions prior to implementation of

Truck and Bus Rule

Excess emissions due to non-compliance with no further

action

0

5

10

15

20

25

30

2010 Today 2023

Die

sel P

M E

mis

sion

s (tp

d)

Full Compliance w/ Truck and Bus Rule

Statewide NOx Emissions from Vehicles Subject to T&B Rule

9

Emissions prior to implementation of

Truck and Bus RuleExcess emissions

due to non-compliancewith no

further action

0

100

200

300

400

500

600

700

2010 Today 2023

NO

x Em

issi

ons

(tpd)

Full Compliance w/ Truck and Bus Rule

Compliance Options in 2020

10

Not many compliance options left:2010 model year or newer engine Commit to a flexibility provision

• Low-use (<1,000 miles/year)• NOx exempt (have diesel

particulate filters and operate only in limited areas)

Components of Successful Implementation

11

New DMV registration process

Compliant/exempt vehicle list

Outreach and enforcement Funding assistance

New T&B Compliance Verification Process

New Registration Process

CARB/DMV handshake. DMV checks:

• Vehicle model year • Vehicle GVWR• Exempt model

codes• CARB’s list of

compliant/exempt vehicles

DMV sends registration renewal notice to:

• Compliant vehicles allowed to register

• Noncompliant vehicle owners notified of status

Noncompliant vehicles

• Referred to CARB for resolution

• Temporary permits to operate can be issued

12

Developing List of Compliant/Exempt Vehicles

13

Includes all vehicles reported to CARB as compliant with T&B Regulation

Includes trucks and buses subject to other regulations

Others that can report through a vehicle verification form• Requires proof, subject to audit

Outreach Goals

Ensure regulated community knows what to expect Direct proactive outreach to

compliant fleets Broad outreach for all

regulated community and public

14

Direct Outreach to Compliant/Exempt Fleets

15

CARB/DMV deadline reminders based on vehicle model yearMailers to exempt/otherwise

compliant fleets who may need to reportMore operators on the diesel

hotline

Broad Outreach

16

DMV Outlets - Videos, posters, and distributable materials

Industry Coordination – Magazines, newsletters, events

TruckStop Website Redesign – Streamlined and intuitive

Media Campaign – Multimedia projects

Media Campaign

17

Digital video ads Digital banner ads Publications Radio ads Billboards Pump toppers Social media

Began November 2018

Funding Assistance

Outreach provides information on funding options

Compliant fleets are eligible for incentive funding

Small fleets are eligible for loan assistance

18

Funding can help fleets attain compliance if they qualify

Promoting Incentive Programs Hybrid and Zero-Emission Truck and Bus Voucher Incentive

Project (HVIP) and Low NOx Engine Incentives Carl Moyer Memorial Air Quality Standards Attainment

Program AB 617 Funds Other Local funds

19

Truck Loan Assistance Program

Low interest loans to truckers who need additional assistance

$103 million from CARB and counting

Leveraged $1.2 billion in financing Over 20,000 loans issued

20

The Role of Enforcement

Identify noncompliance

Notify responsible party

Provide compliance assistance

Take enforcement action if warranted

21

Enforcement Activities

Goal is compliance for a level playing field

Productivity has dramatically increased, but

Tens of thousands of vehicles are currently not compliant

22

Enforcement Challenges

23

• 82,000 California registered vehicles not compliant today

• The average fleet size subject to enforcement is 2 vehicles

California Registered

Vehicles

• Up to 260,000 noncompliant non-California registered vehicles are in fleets that operate in California

Out-of-State Vehicles

Streamlined Truck Enforcement Process

Data driven process informed by vehicle registration, inspection, and compliance reporting data

Using administrative enforcement procedures • Strict time limits to move cases quickly• All communications recorded in a database• Offer due process through administrative hearing• Assess penalties and request registration holds

24

Results to Date:STEP Increasing Efficiency of Enforcement

Five-fold increase in productivity: 20,000 vehicles/year

10,500 fleets covering 20,500 vehicles currently in process

Registration holds issued to 10,000 vehicles

$1.6 million in administrative penalties collected• Penalties assessed at $3,000 per vehicle• Penalties collected range $1,000 - $3,000 per vehicle • Unpaid penalties may be referred to court for judgment

• Collection methods may follow

25

Enforcement Strategy

1. Focused enforcement

2. “Notice to Comply” letters to remaining noncompliant vehicles

3. Targeted warning letters to fleets with vehicles approaching noncompliance

4. Focus inspections on out-of-state vehicles

26

Focused Enforcement

Enforcement on 35,000 vehicles by December 2019

Focus• Chronic noncompliance• Oldest vehicles• Operating in disadvantaged communities

27

Notice to Comply and Warning Letters Send Notice to Comply Letters to remaining 47,000 noncompliant

vehicles

Send Warning Letters to 44,000 currently compliant vehicles that will become noncompliant in 2020

Approach• Certified mail• Specific identification of noncompliant vehicles• Could be subject to enforcement action• Provide compliance assistance information

Registration will be withheld in 2020 as new law implemented

28

Out-of-State Vehicles

29

Focus inspections at border crossings for noncompliant, non-CA registered vehicles• Field staff• Investigating use of automated license

plate readers

Enforcement• Issue and process citations• Identify fleets for audit and enforcement • Coordinate with US EPA

What Happens in 2020

30

New law takes effect

Program staff coordinate with DMV and withhold registration for noncompliant trucks and buses

More than 80,000 California registered vehicles will be impacted

Inspections will be focused at border crossings to create level playing field relative to out-of-state vehicles

Next Steps

Continue working with DMV for a seamless process

Education/Outreach on new process Continue enforcement efforts to

address noncompliance Periodic Board updates on

implementation Protect public health by getting dirty

vehicles off the road!31